Response to consultation on ITS on MREL reporting by Resolution Authorities

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Question 1: Do you consider that any of the components of the ITS Templates presented in the Annex I and Annex II to inform the EBA of the mínimum requirement for own funds and eligible liabilities are not appropriate, and if so why?

The European Association of Co-Operative Banks recognises the reporting of the leverage ratio denominator as a potential backstop. At the same time we believe that both of the annexes shall be determine by the answers of National Resolution Authorities, as they are the data recipient and will proceed with information from the form to the EBA.

Question 2: Do you consider that any additional components are needed to be included in the templates presented in Annex I and Annex II, and if so why?

We do not believe that any additional components to the Annexes are needed, as current components are comprehensive and give detailed overview of the situation.

Question 3: Do you consider it necessary to split the line 190 of the Annex 1 ‘downward adjustment taking into account information received from the competent authority relating to the institution's business model, funding model, and overall risk profile’ into invidual lines for each component i) business model, ii) funding model, and iii) overall risk profile?

We would expect to find in Annex I more granular data received from the National Resolution Authorities relating to business model, funding model and overall risk profile.

Question 4: Do you consider it necessary to add additional lines to gather information on MREL subordination requirements? If yes, how granular information is needed?

Currently, there is no harmonisation of the requirements for the collection of information on MREL at the European Union level. In France, the Sapin II law is still pending. Due to that, the European Association of Co-Operative Banks does not have a preference for the collection of additional granular information. Information on statutory, contractual or structural subordination is sufficient.

Name of organisation

European Association of Co-operative Banks